Energy UK response to Consultation on Minimum Energy Efficiency Standards in the Social Rented Sector in England

Executive Summary

Energy UK welcomes the consultation on minimum energy efficiency standards in the social rented sector (SRS) in England.

The proposed Minimum Energy Efficiency Standard (MEES) will see all properties of this tenancy reach EPC C by 2030, or hold a valid exemption. Investing in the energy efficiency of existing buildings is essential to improving the quality of life and livelihoods of households across England.

The consultation notes that of social rented homes below band C in England, 55% were fuel poor. Furthermore, the English Housing Survey found that 7% of homes in the SRS had problems with damp. Fuel poverty and poor housing conditions can have a detrimental impact on health conditions, educational attainment and productivity.

In addition, reducing carbon emissions from households in the SRS is essential if the Government is to meet its climate change objectives. In the Seventh Carbon Budget, the Climate Change Committee highlights the need for concerted action to decarbonise the heating systems of existing buildings. Introducing the regulations proposed in this consultation is an important policy lever for making progress in this area. These regulations will increase the visibility of the overall quality of housing within the SRS.

Energy UK is seeking to emphasise the need to progress the proposals for Energy Performance Certificate (EPC) reform at pace, alongside the development of the MEES, to ensure that the regulations can be based on the revised metrics. For the same reason, it is important that the development of the Home Energy Model (HEM), and RdHEM that will measure retrofits, are expedited.

The Government should also progress with the rebalancing of policy costs on energy bills. Energy UK’s proposals for policy cost rebalancing would deliver up to a £400 reduction in annual energy bills for a typical household using electric heating, and would make significant progress towards improving energy affordability and decarbonising home heating. With reformed EPCs likely to incentivise efficient forms of electric heating, it is important that tenants in SRS properties benefit from lower bills because of these installations.

Energy UK supports the continuation of the Warm Homes: Social Fund within the Warm Homes Plan. The fund should ensure that social housing providers can invest in decarbonising heating alongside fabric measures. In addition to continued eligibility under a future supplier obligation scheme, this will future-proof the social housing sector while ensuring it can continue to benefit from existing schemes. This would also assist the delivery of an area-based approach.

Finally, we note the read across with the development of heat network regulations. As two-thirds of heat networks are owned by social housing companies, they will be seeking to invest in the operation and efficiency of their networks to ensure that they are providing a good service to customers. Improving the standard of heat networks in the SRS will help to improve the efficiency of the heating system in these homes.